*Dr. Richard Raymond is a former U.S. Department of Agriculture undersecretary for food safety.

I RECENTLY attended the National Institute for Animal Agriculture's (NIAA) Sixth Annual Conference on Antibiotics Used in Animals Raised for Food. Many of the conversations and presentations over the course of the three-day conference focused on midnight on Jan. 1, 2017, when the Veterinary Feed Directive (VFD) takes effect.

Starting then, farmers can no longer use medicated feed containing "medically important" antibiotics — those vital to human medicine — without a veterinarian's oversight and prescription. They also can no longer, as of Jan. 1, use medically important antibiotics as growth promoters, i.e., for production purposes as opposed to therapeutic use.

In 2014, the latest year for which the Food & Drug Administration reported data, sales of these medically important medications comprised 62% of all antimicrobials sold for use in animals, both food-producing and companion animals such as horses, dogs and cats.

Simple math tells us that 38% of all antibiotics sold for use in animals in 2014 were not used in human medicine and were not important to human medicine.

In 2014, of the total domestic sales of medically important antimicrobials, 74% were approved for use in feed, and 22% were approved for use in water, with the remaining 4% or so being approved for use via injection or oral, intramammary or topical use.

That will mean a lot of prescriptions for feed additives, and one of the industry's concerns is how producers will find enough veterinarians to fill the need.

My question is what will happen to total sales of antimicrobials for use in animals. Will the number decline, as FDA hopes?

The Animal Health Institute went on record several years ago with an estimate that 15% of all antibiotics sold for animal use were for production purposes. So, will we see a 15% drop in total antibiotic sales over the next couple of years?

I predict not, for two very important reasons.

The first is actually a bit of good news that no one seems to want to toss out there: Sales of antibiotics for human consumption are already down in some important categories. Comparing 2014 to 2012, sales of penicillin and sulfa, measured in kilograms, were both down about 8%. Fluoroquinolone and cephalosporin, both critical in human medicine, comprised less than 0.3% of all sales for animal use in 2014.

Rounding out the top five classes prescribed in human medicine are macrolides (think Z-Pak), which saw stagnant sales. There was a lot of conversation at NIAA about reducing the use of macrolides to prevent liver abscesses in feedlot cattle.

Still, total sales of antibiotics in 2014 were up about 5% from 2012, with sales up 2% for non-medically important ionophores and up nearly 10% for tetracyclines, an antibiotic comprising less than 3% of sales in human medicine but totaling 70% of all medically important antimicrobials sold for use in animals in 2014.

My guess is that penicillin and sulfa sales are dropping because the poultry industry is already largely separating itself from using antibiotics for growth promotion, but I have no clue why the tetracycline sales have risen so much, considering the impending changes.

It is my guess that when FDA completes it reports for 2015 and 2016 — the last two years before implementation of the VFD rule and limits on growth-promoting antibiotics — sales will have dropped further as the poultry industry, followed by the swine industry, has been reducing the use of antibiotics for growth promotion in anticipation of D-Day 2017.

My second concern is that, instead of using tetracyclines and such for growth promotion, the indications for their use might simply change to "prevention" and "control," and we will not see the anticipated reduction in use reported by FDA. If this is what happens, there will be a high price to pay as consumers and politicians say "we told you so."

It was repeated often at the NIAA conference that "no one wants to see a sick animal go untreated" and how veterinarians take "an oath to protect animals and public health."

First of all, less than 5% of all antibiotic sales go to treat individual sick animals. The great bulk of sales are for prevention and control. In my opinion, the animal agriculture industry better get its talking points ready on that issue, not the issue of letting sick animals go untreated. That is not where the puck is heading. This kind of dialogue will only inflame the adversaries of animal agriculture and contribute to their rhetoric.

It reminds me of a webpage for an agriculture advocacy group that said all antibiotics used on farms and ranches are prescribed by a veterinarian and under the vet's direct supervision.

Second, medical doctors (MDs) also take an oath to protect the public's health, but that point was not in the discussion. Instead, it was often repeated that 30% of prescriptions written by MDs were unnecessary. I won't deny that possibility, but I will ask what makes the veterinarian's oath so much more morally and ethically strong and correct than the Hippocratic Oath?

It was also brought up that a pediatrician has a hard time turning down a mother's request for an antibiotic for her little child who is febrile and crying because of ear pain from otitis media.

Does a veterinarian have an easier time telling the chief executive of a major protein-producing company (who controls the vet's financial future) that the flock or herd does not need an antibiotic?

Many speakers at NIAA said their companies use antibiotics only in a judicious, cost-effective manner. When most are sold as over-the-counter antibiotics, that is another tough argument to make to consumers who are worried about the effects on their family's health resulting from using a large amount in animals.

With a 5% increase in sales of antibiotics for use in animals over the last two reported years, the "judicious" rhetoric rings rather hollow.

Jan. 1 is going to be a very huge date in the future of animal agriculture, and I hope the industry can handle the challenges in a positive and game-changing fashion, but what I have seen causes me concern that it is not ready for an open, honest discussion.

If the industry can't get ready, this war over antibiotic use in animals just might be lost in the next five years.

Volume:88 Issue:12